Invoicing in Denmark without a CVR number: how to do it legally

The Danish terms you will meet

Danish tax rules use a handful of terms that have no clean English equivalent. They are used as-is below, so here is what they mean:

CVR

The Danish business register and the number a registered business receives. Registration is free at virk.dk.

CPR

Your personal identification number.

Moms

Danish VAT, 25%.

Honorar

Fee income: payment for personal work done outside an employment relationship that is not a business either.

A-indkomst / B-indkomst

A-income has tax withheld by the payer (salary). B-income does not — you report it and pay the tax yourself.

Skattestyrelsen

The Danish Tax Agency.

Fakturabureau

An invoicing bureau, also called an umbrella company: it invoices on your behalf and employs you for the job.

Short answer: yes — if the work is fee income

There is no rule saying you need a CVR number to demand payment for a piece of work. An invoice is, in itself, just a payment claim: a document telling the customer what they owe you and how to pay.

So what decides your situation is not the invoice. It is how your income is classified for tax purposes. There are three boxes, and you are in one of them:

• Employee (lønmodtager). You work in an employment relationship under the employer's instruction. Then you should not invoice at all — you receive a salary, and A-tax is withheld when it is paid out.
• Fee earner (honorarmodtager). You perform personal work outside an employment relationship, but it is not an independent business. The income is B-income. This is where you can invoice without a CVR.
• Self-employed (selvstændig erhvervsdrivende). You run a business for your own account and risk, systematically and with a view to profit. Here you need a CVR number.

When is it fee income — and when is it a business?

The Tax Agency's legal guide defines fee income as "payment for personal work performed outside an employment relationship, which does not stem from independent business activity either". The fee is paid out as B-income by default (Den juridiske vejledning C.A.3.1.2, in Danish).

The line between fee income and a business is not an amount — it is an overall assessment of how you actually work. These factors point towards fee income:

• One-off or sporadic jobs, not an ongoing operation.
• You carry no particular financial risk beyond your own time.
• You have no operating costs to speak of, no employees and no subcontractors.
• You do not market yourself systematically to win jobs.

And these point towards a business: you seek out jobs systematically, you advertise, you invest in equipment, you have several clients on an ongoing basis, and you carry a real financial risk.

A couple of fees a year for an association or a company is typically fee income. Freelance work as your main income, month after month, is a business — even if you never registered a CVR number. The classification follows reality, not the registration. If you are unsure where you sit, that is exactly the kind of question the Tax Agency or an accountant has to settle for you.

What must the invoice contain — and what must it not?

Here is the most important rule, and it is often overlooked:

You must not put VAT on the invoice. Under section 52 a(6) of the Danish VAT Act (momsloven), taxable persons who are not registered may not "state a tax amount on the invoice or otherwise indicate that the invoice amount includes tax". If you do so anyway, section 52 a(7) requires the amount to be paid to the Tax Agency — unless the error is corrected towards the buyer (momsloven § 52 a, in Danish). So: no VAT rate, no VAT line, and no "incl. VAT" anywhere on the document.

The formal invoice requirements in section 57 of the VAT order (momsbekendtgørelsen) apply to VAT-registered businesses, so not to you. But your customer has to be able to book the document and report the payment, so include these fields:

• Your full name and address.
• Your CPR number — the payer typically needs it to report the fee as B-income.
• The customer's name, address and CVR number.
• Invoice date and a sequential invoice number.
• A description of the work and the period it covers.
• The amount — without VAT.
• Payment deadline and your payment details (registration and account number, or MobilePay).
• A short line such as: "The amount is B-income. No VAT has been added, as the issuer is not VAT-registered." (In Danish: "Beløbet er B-indkomst. Der er ikke tillagt moms, da udsteder ikke er momsregistreret.")

About the CPR number: it is sensitive personal data, so send the invoice directly to the person who will pay it, and avoid sharing it more widely than necessary. Ask the customer whether they have a secure channel for it.

If the customer does not pay by the deadline, the same rules on reminders and reminder fees apply as for any other invoice — see the guide Rykker og rykkergebyr (reminders and reminder fees, in Danish).

The VAT threshold: 50,000 kr in a calendar year

Section 71 e of the VAT Act exempts you from the registration duty "when the annual turnover in this country (…) does not exceed 50,000 kr." Turnover is measured per calendar year — 1 January to 31 December, not a rolling 12 months. The threshold applies to both the current and the preceding calendar year: if you exceeded 50,000 kr last year, you must register for VAT even if you are below it this year (Den juridiske vejledning D.A.14.2.2.2, in Danish).

Two things are often mixed up here:

• The threshold is about VAT — not about income tax. All income must be reported to the Tax Agency from the first krone, however small. The 50,000 kr only decides whether you have to charge and settle VAT.
• The threshold does not exempt you from having a CVR. If your activity really is a business, the business must be registered, even if turnover is below 50,000 kr. It just does not have to be registered for VAT.

If you cross the threshold, you must register for VAT, add 25% VAT to your invoices and settle it with the Tax Agency. In return, you can then deduct the VAT on your business purchases.

The honest fork: fee income, invoicing bureau or your own CVR

There are three routes, and each fits a different situation:

1. Stay on the fee-income track. Fits a few jobs a year without systematic business activity. It costs nothing, but you are responsible for reporting the income correctly yourself, and you cannot add VAT.
2. Use an invoicing bureau (fakturabureau). The bureau issues the invoice on your behalf, and you effectively become their employee. They invoice with VAT, withhold A-tax and the 8% labour-market contribution (AM-bidrag), set aside holiday pay, and typically include professional liability and occupational injury insurance. Relevant if you do not want a CVR, or if the customer requires an invoice with VAT.
3. Register your own CVR. Registering a sole proprietorship (enkeltmandsvirksomhed) is free at virk.dk. You handle VAT, bookkeeping and tax yourself.

Let us be honest about the trade-off: an invoicing bureau removes real administrative work. Tax, VAT, holiday pay and insurance are handled for you, and that has a value — especially if you have few jobs or are new to freelancing. Your own CVR is not in itself "simpler"; you take those tasks on yourself. In return, you do not pay a percentage of every single invoice.

The arithmetic: when does the economics turn?

The bureau fee is a percentage, so it grows with your turnover. Your own CVR, by contrast, comes with roughly fixed costs. So there is a crossover point, and it depends entirely on which fixed costs you take on. Here is the arithmetic, so you can check it against your own numbers:

1. With a free invoicing tool. If you keep fixed costs down to a business bank account (typically around 140–245 kr/month), a 6% bureau fee equals that cost at invoicing of around 2,500–4,000 kr/month.
2. With paid accounting software. If you add a classic accounting package at around 350 kr/month on top of the bank account, fixed costs are about 490–595 kr/month. That equals 6% at invoicing of around 8,000–10,000 kr/month.

Where PennaPay fits in

PennaPay is invoicing software, not an invoicing bureau. We do not issue the invoice on your behalf and we do not handle your tax — you send the invoice yourself, and you are responsible for reporting the income. In return, there is no CVR requirement to get started:

• The CVR and VAT field is optional when you create an account.
• You do not need an account at all to use the free invoice generator.
• Free plan: 5 invoices, with no payment card required.
• 16 templates to choose from.
• MobilePay is supported as manual payment details on the invoice — online card payment is coming soon.
• Your data is hosted in the EU and processed under the GDPR.

If you start without a CVR and set up a business later, you simply add the CVR number to the same account. Your history is kept, and the account is then ready for B2B invoicing with VAT — and for Danish e-invoicing when it launches.